关键词: 人工智能, 安全治理, 国际经验, 路径启示

Abstract: With the rapid proliferation of generative Artificial Intelligence (AI), large-scale models, and intelligent-agent applications, AI security risks have permeated data processing, model development, product deployment, and infrastructure operation. Accordingly, this study analyzed the characteristics and implementation approaches of AI safety governance in major countries and regions, and found that although the choices of governance measures vary significantly due to differences in technological foundations, legal traditions and security environments, convergent practices exist in fields including data privacy, algorithmic models, generative content, tiered regulation and technology supply security. This comparative study of international practices can provide valuable insights for China to refine its artificial intelligence safety governance system.

Key words: Artificial Intelligence, safety governance, international experience, policy insights